First take on radiation oncology APM mixed
Another thing that stood out as concerning was the start date, which CMS suggested could be as early as January 2020, but it also suggested that could be pushed back to April 2020. Practices won’t know if they are selected as required to participate until the final rule is issued, likely in November.
“We are pleased that CMS seems to be open to considering an April 1 start date,” he said. “That’s probably the earliest that it could start,” adding that ASTRO might look to see if there is an opportunity to encourage CMS to implement a rolling start date.
He also noted that CMS did not include any sort of hardship exemption for practices that have a rationale for not wanting to or being able to participate.
That, and including a voluntary participation option, “can be done without compromising the evaluation of the model.”
That being said, Mr. Adler spoke positively in general.
“We are moving in the right direction here with the model,” he said. “We are very much committed to working with CMS and our champions in Congress constructively to improve upon what has been proposed here.”
One thing he liked was the prospective payment aspect of the model.
“Radiation oncology practices, given the expense of the equipment, the staff, and the delivery of the sophisticated treatment requires a huge up-front expense,” he noted. “The ability to have this up-front payment prospectively is something we recommended, and it is very good to see that in there.”
He also spoke positively of the quality measures that are part of the proposed model.
“They really seemed to have zeroed in on meaningful measures for radiation oncology practices ... things that are really connected to guidelines that are known to support patients,” he said. “We didn’t see anything in the list of quality measures that are off base. That was a real positive [and] consistent with things that we have recommended that CMS should consider on the quality front.”
He also said the structure of the model will drive more guideline-concordant care, and incentives are there that will make treatments more convenient for patients.
“There are some positive aspects here that we can really build on,” Mr. Adler said.
